Notice of Petition - "Compensation, Retirement Programs and Related Benefits" Gary Baldosser 5120 N TWP RD 78 Republic, OH 44867
April 21, 2013
Barry F Mardock Deputy Director, Office of Regulatory Policy, Farm Credit Administration 1501 Farm Credit Drive McLean, VA 22102-5090
Dear Barry Mardock:
Thank you for requesting comment on the regulatory petition filed by The Farm Credit Council regarding the Agency's say on pay mandatory shareholder vote on compensation matters.
As a director of the Ag Credit Association in Northwest Ohio, a Farm Credit System institution, I support the request contained in the Council's petition that the agency withdraw the say on pay vote requirement.
Asking shareholders to vote on matters that are the defined responsibilities of the board of directors is inconsistent with the Farm Credit Act and its cooperative principles. It undermines the role and responsibility of directors to represent the interests of shareholders and increases litigation exposure for directors and institutions. Shareholder engagement on compensation matters already exists through the disclosure requirements that are in place and the ability of shareholders to express their views on these matters to management and boards at any time. Association Directors spend a lot of time training and educating themselves on how to govern prudently and effectively. Just as Congress or the Senate is ultimately accountable to the tax paying public, we too are held to a higher standard than other banking institutions by our VOTING MEMBERS!. They elect us to make these decisions because they recognize they are not engaged at a level that gives them comport to make these decisions as an individual. If you honestly believe this to be in the best interest of the entire Farm Credit System, then let us expand this idea, and ask that all FCA employees offer their personal salaries open to a public vote by the residents of The United States. Let the tax paying public have a voice in how pay is distributed in the Farm Credit Administration. I am sure with enough effort on your part, we can fully educate every resident on the aspects of defined benefit packages, market based salary ranges, peer review process, job satisfaction surveys, and all legal issues that surround your human resource department.
Please modify the final rule on compensation and benefit program disclosure to remove the requirement for say on pay voting.
This rule on compensation voting will only erode the effectiveness the Farm Credit System has worked so hard to establish the past 60 years.
Gary Baldosser Director of Ag Credit ACA 419.483.2097